8.2.1 Customer agreement
Where relevant, the contract to process personal data must address the organization's role in assisting the customer with the customer's own obligations, taking account of the nature of processing and the information ava
4
artefacts
0
held by a system
1
at each review
hard
to go live
Vendor register / contract repository
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- Contract register reconciling signed terms to live processing engagements · Vendor register / contract repository
governing documentDocuments that govern the control
- Customer contracts carrying the assistance provisions relevant to the engagement · Vendor register / contract repository
- Where the jurisdiction requires it, contract terms stating subject matter, duration, nature, purpose, data types and categories of individuals · Vendor register / contract repository
- Operational capability behind each assistance commitment, not the commitment alone · Vendor register / contract repository
First move
This control is evidenced by people and documents, not systems. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date. Do not try to automate it.
Common gaps auditors find
- Assistance promised in contract with no operational capability behind it, discovered only when the customer first asks
- Breach notification assistance limited to telling the customer, with none of the detail the customer needs to notify a regulator
- Impact assessment assistance omitted, leaving the customer unable to complete one
- Jurisdiction specific content requirements unidentified, so the contract is incomplete where it matters
- Legacy customers on older terms that predate the obligations
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
Build my evidence sheet7.5.4 Records of PII disclosure to third parties · 8.2.2 Organization’s purposes